Waste Exemption Changes July 2024

Waste exemptions are changing from July 2024 as part of the Environment Agency’s (EA) drive to reduce pollution and illegal dumping of waste.

Farmers often register multiple exemptions ‘just in case’.   It is worth noting that you do not need to register exemptions for storing waste on your farm where it was produced.  This type of activity is covered under the Non-Waste Framework Directive (NWFD) exemptions.

Under the NWFD you can store waste in a secure place at the place of production, and separate recyclables such as paper, card, plastic and glass.  Notably for most farmers this means plastic containers (washed), black plastic and baler twine.

• It is worth noting you cannot store waste on your site if was produced somewhere else.  Take care if operating over multiple registered holdings (using different County Parish Holding Numbers).
• It must not be stored for longer than 12 months.  Take care not to allow large build ups when recycling.

In practice the EA will be looking for farmers to store waste in a suitable area, preferably contained.  This can be in a contractors skip that is fenced around the outside or in old barn or lean to.  They must not allow waste to build up to large quantities on inspection.  Proof of disposal in the form of a waste transfer note will suffice that waste is being treated properly and in a timely fashion.  These should be completed by the haulier when the waste is picked up but are also often clipped to the back of invoices from waste carries.

It is worth noting that changes to exemptions U1 use of waste in construction and exemption D7 burning waste in the open, have been made clearer and easier to interpret.

Under U1 farmers can use building material for bunds tracks and roadways.  Under the changes individuals can’t use more waste than you need and be able to justify the amount needed.  Waste cannot be stored any longer than 12 months before you use it.

Under D7 farmers can burn up to 10 tonnes of waste outside in any 24-hour period, and store up to 20 tonnes of waste at any one time.  Waste cannot be stored for more than 6 months before burning.  Under the exemption bonfires should carefully positioned where it will not cause nuisance to neighbours through excessive smoke or odour, and the burning must take place where the waste is produced.

Slurry and FYM aren’t considered waste if they are used to improve soil or support plant growth.  Under the Farming rules for water the application of organic manure must be planned so that the application does not exceed the needs of the soil and the crop on the land.

Whilst there is no legal requirement to have a physical nutrient management plan, it is hard to demonstrate that slurry is not being treated as a waste or compliance without one.  A nutrient management plan will give the required application rates of all the organic and manufactured nutrients, to all the crops across the farm.  It shows the farmer has taken weather, soil analysis and pollution risks into account before any work has been carried out.

According to the EA 30% of farms inspected couldn’t provide evidence of how they plan to spread fertilisers or manures on their land.

Treat Slurry and FYM as a nutrient which will either grow more crop or reduce purchased fertilisers.  Don’t just do a nutrient management plan for compliance or SFI payments, put one in place, use it and save money, target the right nutrients to the land areas and crops that need it and reduce your carbon footprint as a result!

Contact Allaster Dallas, FACTS qualified consultant at allasterdallas@fcgagric.com  to help you save money on fertiliser with a Nutrient Management Plan today and turn a Compliance requirement into a Plan to Save Money on Fertiliser!

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